ds. Eventhese few no-fault legislative provisions, however, were interpreted narrowly bythe courts; whenever possible, the fault-based notions of traditional doctrinewere read into no-fault legislation. The realities of divorce litigation in the U.S.,however, were actually quite different from the legal requirements. Trial judgesand lawyers, pressed by a society that in fact wanted free divorce and yetretained publicly the ideal of until death do us part, for many decadesoperated a legal system that permitted spouses to terminate their marriageswithout proving grounds if both parties wanted the divorce. Thisconsensual-perjurious divorce was obtained by having the plaintiff in effect lieabout grounds without objection from the defendant. As divorce became lessstigmatizing and as serial marriages became more common, the burden onlawyers and judges to maintain a fictional fault-based divorce system becameeven greater. The grounds for divorce differed from one state to another; thus,for example, before 1967 the only grounds for divorce in New York State wasadultery. Moreover, judicial and public attitudes toward consensual-perjuriousdivorce varied from state to state. The difficulty of obtaining a divorce inseveral of the more populous eastern states, such as New York, New Jersey,Massachusetts, and Pennsylvania, eventually led to a substantial amount ofmigratory divorce in so-called divorce havens. For instance, a six-weekgambling sojourn in Reno, Nevada, could culminate in a divorce and a returnto the state of original home. Before extensive legislative reform, somespouses living in states where divorce was difficult to obtain would travel tojurisdictions outside the continental United States (usually Mexico, Haiti, or theDominican Republic) for a divorce decree that had none of the constitutionaladvantages, for purposes of local recognition, of a decree from another state. New York State courts were the only ones to extend formal reco...
